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Product Tracing in Food Systems & Mock Traceback IFT Recommendations to FDA. Sarah D. Ohlhorst, MS, RD IFT Staff Scientist

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(1)

Sarah D. Ohlhorst, MS, RD

IFT Staff Scientist

Product Tracing in Food Systems &

Mock Traceback

(2)

Overview

 Who is IFT and what were we asked to do

 Key findings and recommendations

 Mock tomato trace-back exercise

(3)

What is IFT?

 Institute of Food Technologists

 Scientific and professional society

• Individuals in food science, food technology, and related

professions; working in industry, academia, and government

• Over 18,000 members

 Offices in Chicago, IL, and Washington, D.C.

 Contract work with FDA since 1999

• TO6 on product tracing issued Oct 2008 • TO7 mock trace-back issued June 2009 • Both tasks submitted Sept. 15, 2009

(4)

What is Product Tracing?

 The ability to follow the movement of a food through specified stage(s) of production, processing, and

distribution

 Companies typically record what

they receive and who they received it from, and what they ship and who

they shipped it to

 Economic and public health impacts

• Immediate: trace food forward to prevent sale

and consumption

• Preventive: trace food back to determine cause

of the issue, and prevent it from happening again

(5)

Task Scope of Work

 Identify current and future product tracing systems (US and international; food and other industries)

 Review from harvest through processing and distribution to points of service

• Beyond BT Act

• Focus on produce and FDA-regulated food products

 Examine accessibility of information to public health regulatory officials

(6)

• Stephen Arens, MBA; GS1 US, NJ

• Frank Busta, Ph.D.; National Center for Food Protection & Defense,

MN

• Martin Cole, Ph.D.; Formerly with National Center for Food Safety &

Technology, IL

• Art Davis; Formerly with The Sholl Group/Green Giant Fresh, MN

• Helen Jensen, Ph.D.; Department of Economics, Iowa State

University, IA

• Brenda Lloyd; UFPC/YUM! Brands, KY

• Benjamin Miller, MPH; Department of Agriculture, MN

• Gale Prince; Formerly with Kroger; Your Food Safety Coach, OH

Subpanels: State Trace-back Investigators; Food Industry; Agricultural Economists; Systems/Technology Experts

Task Approach: Collaborated with Core

Expert Panel and Subpanels

(7)

• 55+ food companies throughout the supply

chain

− Animal feed

− Produce

− Ingredients & Processed foods

− Distributors

− Retail & Foodservice

• Trade associations • Consumer groups

• Technology providers

Task Approach: Engaged Over 200

Stakeholders

(8)

Questions Answered

1. What systems and technologies are out there? 2. What is done in other industries?

3. What is required in other countries? 4. What are food companies doing?

5. What should food companies be doing?

6. How much will it cost to implement full product tracing?

(9)

Assessment of technologies

 3 categories of solution providers

• Cold chain management; other quality/ safety-related

service

• Provide medium/ unique identifiers • Software as a service

 Technologies in use to be adapted

• Accounting • Batching • WMS, etc.

• Some custom or legacy in-house systems

(10)

Other Industries Explored

 Automotive  Pharmaceutical  Toy industry  Parcel  Clothing  Appliance  Animal identification

(11)

Findings from around the globe

 Codex documents and ISO standards

 EU, Canada, Australia, other developed regions have explored product tracing

 Private tracing initiatives worldwide

 Rest of the world - some lack food safety regulatory structure

(12)

Key Findings

 Food production and distribution are global and complex

 Technology to trace exists, and continues to evolve

 Most firms believe they are in compliance with

“Bioterrorism Act” (maintaining 1-step up/back records)

 The lack of common data elements in the supply chain may not provide complete product tracing

 Paper recordkeeping is prevalent, dominant

 There are many industry initiatives, current and in development

 Product tracing costs vary, tend to be inaccurately estimated

(13)

Overarching Issues

 Paperwork generally lacks complete information

• No standards exist for capturing/expressing information

 Within a facility, internal systems often differ and are not electronically linked – not interoperable

 Companies receive different information from different suppliers, and have to provide different information to different customers

 “Lot” – meaning is confused and internal tracing is prevented

(14)

Barriers and Motivators to Tracing

Barriers

 Suppliers don’t routinely provide information

 Customers uninterested

 Bulk/commingling

 Lack of data sharing standards  Cost

Motivators

• Fear of regulation or imposed standards • Improvement of other processes (inventory control) • Improvement of consumer confidence • “Cost to do business”

(15)

How product tracing impacts regulators

 Quickly, accurately locate the source

• If not, increase exposure and can’t determine the cause

 Quickly, accurately determine the scope

• If not, consumer exposure continues and industry

“damage” remains broad

 Provide targeted consumer advice

 Reduce multiple recalls after initial recall

 Currently struggle with one up and one back

(16)

IFT Guiding Criteria

 Simple

 User friendly

 Leverages existing industry systems

• Controls cost

• Increases likelihood of adoption

 Globally accepted

• Standardized ways to express key data elements • Suitable for global food supply (not US centric)

(17)
(18)
(19)

Barcode vs. RFID

(20)

IFT Core Recommendations

 Identify Critical Tracking Events (CTEs) when product is moved, transformed, etc.

• Similar in concept to Hazard Analysis and Critical Control Points

(HACCP) already widely used throughout food industry

 Maintain records for each CTE in agreed upon, standardized formats that link incoming/outgoing product

• This ensures “internal tracing”

 All firms should be able to provide key data elements for all CTEs in an electronic form, within 24 hours of request by FDA

 Training/education on CTEs and key data elements should be developed

 Product tracing should be required part of regulatory or 3rd

(21)

M an uf ac t ure r D is tri bu to r O per at or

Ingredients - Raw Materials

Foodservice Supply Chain Critical Tracking Events (CTEs)

Item Tracing Production Packaging Inventory Storage CTE Receipt CTE Shipping CTE Receipt CTE Shipping CTE Delivery CTE Case Opened Prep Transfer Waste

(22)

Firms’ Perceptions of Cost

Generally couldn’t provide estimates

“expensive”

Often assigned costs to things other than

product tracing

Very few data exist

© 2010 Institute of Food Technologists

(23)

Benefits vs. costs at the firm level

© 2010 Institute of Food Technologists

23

Benefits

• Improved supply chain management

• Inventory control

• Access to contracts and markets

• More targeted recalls

Types of costs

•Capital investment and start up

•Software and associated fees

•Equipment

•Consultants

•Labor and training

•Materials and supplies

(24)

Costs: Sector and Societal Implications

 Societal costs

• Lower healthcare costs: loss of life • Loss of consumer confidence

• Major psychological and emotional damages due to

massive outbreaks

• Indirect loss in economic output and productivity losses

 Additional considerations

• Loss of market share if traceability systems are not similar

for whole sector

• Lack of adequate capital, labor, and technology expertise • The probability of occurrence of a triggering event/year vs.

(25)

Another Product Tracing Task

 Scope of work: Conduct mock trace-back/ forward of tomatoes using existing data from entire supply chain and visualization software

 Tomatoes selected due to 2008 Salmonella

saintpaul outbreak

 Subcontracted with Harvard, Microsoft, TIBCO

 FDA and tomato supply chain participated

 IFT’s portion of the task was to do a comparison with other technologies

(26)

What we asked technology providers

 The ability of each platform to store data, including how much data can be stored

and for how long;

 The management of all data;

 The ability of the system to accept data in multiple formats;

 How data are shared and how access is enabled or restricted;

 If product tracing extends from points of service to points of processing and

production through point of sale;

 The precision of the platform to locate a source of contamination, product’s

movements or characteristics and more;

 How quickly information (source of contamination, etc.) can be provided and

communicated; and,

(27)
(28)

Mock Trace-back/ forward Summary

 Findings:

• Data exists

• How FDA would receive data is TBD

• “QA” of data was substantial (standardizing date,

for example; making sure it matched up, etc.)

• Visualization showed potential to expedite

trace-backs/ forwards (as long as data were good)

• There are many commercially available systems

that could be tested using these data

(29)

Moving Forward

IFT’s full reports available at

 FDA/FSIS collected public comments

 Many industry initiatives are underway

 What will Congress do?

 Clear objectives must be set for members of the food supply chain

 Allow industry to determine how to reach those objectives

(30)

Thank You!

Any Questions?

(31)

© 2010 Institute of Food Technologists

Headquarters

525 W. Van Buren Street Suite 1000 Chicago, IL 60607 312.782.8424 ift.org Washington, D.C. Office 1025 Connecticut Avenue, NW Suite 503 Washington, D.C. 20036 202.466.5980 ift.org

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